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    OUR COMMITMENT TO PRIVACY

    Sarkli-Repechage, Ltd. understands and respects your concerns about privacy and we strive to protect your information.  This privacy policy ("Privacy Policy") describes our practices with respect to information we collect about you.  We would like you to know what type of information we collect about you and how we use, process and store that information.  This Privacy Policy also explains your rights and choices with respect to the way your personal information is collected and used.  Your visit to www.repechage.com ("the Site" or www.repechage.com) is subject to this Privacy Policy and to the Site’s Terms and Conditions.  By using this Site, you agree unconditionally to be bound by this Privacy Policy and by the Site’s Terms and Conditions.

    1. WHO WE ARE

    For purposes of applicable data protection laws, Sarkli-Repechage, Ltd., a New York corporation, with offices located at 300 Castle Road, Secaucus, NJ, USA is the data controller under this Privacy Policy.   

    1. THIRD PARTY SELLERS

    Our products are also available for sale by third parties (including, without limitation, distributors, salons, spas and beauty schools) in the USA and internationally.  Unless otherwise indicated, any information collected by such third parties is not provided to us and is not subject to this policy.  Any information collected by third parties is subject to their respective privacy policies.

    1. WHAT IS PERSONAL INFORMATION?

    Personal information (or personal data) is information from which a person can be identified.  This includes, for example, your name, email and address.  Non-personal information (or non-personal data) is information where the identity has been removed – that is anonymous or aggregated data.  This includes, for example, aggregated information about the number of users accessing a specific page on our website.

    1. WHAT INORMATION DO WE COLLECT?

    Information That You Provide To Us: We may collect personal information from you when you enter it on our website or provide it to us in any other way.  For example, you may provide personal information to us when you register, use or purchase on our website, update your contact details, use our social media pages, use our mobile site, sign up for a newsletter or mailing list, sign up for discounts, promotions, alerts or other marketing communications, enter an offer or promotion, enroll or participate in a webinar, online or live training, trade shows or events, or contact us via social media, email or chat.  Information that we collect may include the following types of personal information that you share with us:

    • Name, email address, mailing address, telephone number, mobile number
    • Age and/or date of birth
    • Gender
    • Username/Password
    • Zipcode
    • Delivery address, billing address.
    • Payment information (i.e., credit card number, expiration date and security code)
    • Skincare preferences or concerns
    • Skin type
    • Purchase history
    • Product preferences
    • Professional license (cosmetology, esthetics, etc.)
    • Contact information of family of friends (for example, if you are sending a gift). Please be aware that you must obtain the consent of other individuals before providing their personal information to us.
    • Information or content you provide (photos, reviews, comments, surveys videos etc.), including information or content provided via our social media pages.
    • Other information that you provide about yourself through the Site, email, social media or other communication.

    Information That We Collect Automatically: We and our third-party service providers may automatically collect and store certain information about your usage or device when you visit the Site, view our emails, view or click on our online advertisements or visit our social media pages, using various technologies, such as cookies, that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device.  For example, we may collect your IP address, device identifier, web browser software and referring website.  We may also collect and keep track of your online activity, such as searches, pages visited and content viewed.  This helps us analyze and improve our Site, products, services and marketing.

    Information Provided By Third Parties:  We may receive information about you from third party sources, including business partners or third parties that provide services our behalf.  For example, our shipping carriers or other third parties may update your delivery and address information; third parties may provide analytics and usage information about your usage of the Site; third parties who conduct customer surveys will share the information provided through the surveys; and third parties may share information about you if you “click-through” from their Site to ours.  Also, if you communicate with us on social media by posting to our social media pages, tagging us or otherwise interacting with us, we may collect information from the social media account you use to communicate with us depending on the social media platform and your account settings.  For example, we may collect the name and handle associated with the account, the content of any posts in which we are tagged and other information available on your profile.  We use this information to respond to your posts and stay connected with our audience.

    1. HOW DO WE USE YOUR PERSONAL INFORMATION?

    We will use your personal information for service and business-related purposes, including:

    • Account set up, management and administration
    • Order fulfillment
    • Processing and delivering your order
    • Payment processing
    • Offering, providing and improving products and services
    • Providing customer service
    • Enrolling you in, or administering, training, live events or webinars
    • Entering you in, or administering, contests, promotions or giveaways
    • Rewards programs; Loyalty programs
    • Gift certificates
    • Recommendations, personalization of content and user experience
    • Communicating with you about your account, use of our Site and services and sending updates
    • Notifying you of promotions and special offers
    • Responding to your inquiries
    • Posting your reviews
    • Displaying your purchase activities via sales notification pop ups
    • Marketing and events communication
    • Customer satisfaction surveys
    • Notifying you of change to our Terms and Conditions or Privacy Policy
    • Fraud prevention
    • Legal or financial obligations
    • Internal business purposes
    • Research and development

    We may also ask for your consent to use your personal information in other ways that we specifically communicate to you at the time of collection.

    1. MARKETING
    • Communications to Serve You. If you decide to provide us with your contact information by contacting or emailing our Customer Service department, placing an order, registering for the Site, signing up for training, or otherwise providing your contact information, we may contact you regarding your customer service requests, inquiries or your order, and we may, from time to time, send you service-related announcements concerning the Site.  These communications are part of our effort to serve you and respond to your questions and concerns.
    • Marketing Communications.
      • Opt-In Email. If you decide to "opt-in" either during registration or at other times when you submit personal information, the information you provide may be used by us to send you emails, including newsletters, promotions, discounts, new product information etc. ("Opt-In Email"). If you do not wish to receive Opt-In Email, please do not opt-in to receive these emails.
      • Opt-Out of Emails. You may opt-out of receiving marketing emails when you register for the Site or submit personal information. If you choose to opt-in and later decide that you would no longer like to receive these emails, you may opt-out by clicking the "unsubscribe" link at the bottom of any Opt-In Email you receive from us and following the instructions provided therein or by sending your opt-out request to info@repechage.com.
      • Please note that even if you opt out of receiving marketing communications, we will continue to send to you emails or communication regarding your orders, service-related announcements concerning the Site or updates to our policies.
    1. WHAT LEGAL BASIS DO WE HAVE FOR USING YOUR PERSONAL INFORMATION?

    We use your personal information based on the following legal grounds:

    • Performance of a contract - where we are about to enter into or have entered into a contract with you, such as when you order products or services.
    • Our legitimate interests – this means our interest in managing our business and providing high quality products and services.  For example, marketing activities, data analytics, research, internal administration and processing legal claims. 
    • With your consent – where you agree to allow us to use your information.  For example, if you choose to store a credit card, password, username etc.    
    • To comply with a legal or regulatory obligation – where there is a legal or regulatory obligation to share your information.
    1. WHEN DO WE SHARE YOUR PERSONAL INFORMATION?

    Your personal information is important to us and we will not share it, except as necessary to conduct our business operations and provide our products and services. 

    We may share your personal information as described below:

    • Third Party Service Providers. We may, from time to time, retain various service providers to perform certain functions on our behalf which involve collection of information, including (but not limited to) customer support specialists, web-hosting companies, payment processers, analytics, public relations, marketing, advertising companies, fulfillment companies (for tasks such as fulfilling product orders or coordinating mailings) distribution of surveys and email service providers. We may also retain third-party vendors to collect personal information on our behalf, as necessary to operate our Site, optimize and manage our internet business, measure the effectiveness of our advertising and how visitors use our website.  We do not authorize these third party service providers to use the information except as necessary to perform their functions and comply with legal or regulatory requirements. 
    • With other third parties with your consent.
    • When You Contribute to the Site. We may store your reviews, ratings or, if applicable, any other contributions to the Site (collectively “Content”) and publicly display such Content and use it for promotional purposes.  Please be aware that if you include personal information in your Content (such as your name in a review), it can be used and viewed by others.
    • Compliance with Law. We may disclose any information, including personal information, in order to comply with any applicable law, regulation, legal process or governmental request.
    • Fraud Protection. We may provide information, including personal information, to certain other companies and organizations for purposes of credit fraud protection.
    • Sale of Business Assets. As we further expand, we may merge with another company or sell some or all of our business assets to another party as part of a business transaction. In such transactions, user information, including personal information, generally is one of the transferred business assets, and by submitting your personal information on the Site you agree that your data may be transferred to such parties in these circumstances.

    We will not:

    • Rent or sell personal information that we collect about you to third parties for their use in marketing their products or services without your consent.
    1. NON-PERSONAL INFORMATION

    We may use the information you provide in aggregate form, that is - non-personal information, for developing marketing plans and generating statistics or for other internal business purposes.  We may collect or store certain non-personal information concerning your use of the Site, including information about which of our pages are most visited.  We may share non-personal information with third parties for any lawful purpose.  If we combine aggregated data with your personal information so that it can identify you, we will treat the combined data as personal information.

    1. WHERE DO WE STORE AND PROCESS PERSONAL INFORMATION?

    Our Site is operated in the United States and intended for users located in the United States.  The information we collect, including personal information, will be transferred, processed and stored both in the United States in countries outside of the United States (including, without limitation, Canada) which may not provide the same level of protection for your personal information as your home country.  By using this Site or providing us with any information, you consent to the transfer, processing and storage of your personal information in the United States and other countries outside the United States (including, without limitation, Canada) which may have different data protection laws than in your country and you acknowledge that your information may be subject to access by law enforcement, national security authorities and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.  For transfers of data out of the European Economic Area, we will take precautions to ensure that your personal information is adequately protected by implementing appropriate safeguards, such as standard contractual clauses, and, as appropriate, other applicable mechanisms.

    1. HOW DO WE SECURE PERSONAL INFORMATION?

    The security and integrity of your personal information is important to us.  To that end, we have implemented and maintain appropriate technical, physical and organizational measures to ensure an appropriate level of security for your personal data, including protection against unlawful or unauthorized access, destruction, alteration, loss, damage, disclosure or use.  However, no security system can be guaranteed 100% and we cannot promise that the personal information you provide to us will be secure at all times, including, without limitation, the security of your information during transmission over the internet.  We ask that you notify us if you experience any unusual activity that may indicate a security breach.  Upon your notification, we will investigate the reported activity to determine whether it is related to Sarkli-Repechage, Ltd. and advise you as to what steps can be taken to help resolve the issue.

    1. HOW LONG DO WE KEEP PERSONAL INFORMATION?

    We will keep your personal information for as long as necessary to fulfill the purposes that we collected it for, as may be required by law such as for regulatory, accounting, reporting or other legal requirements, or as otherwise communicated by you.  We consider several factors when determining the appropriate retention period for personal information, including: the amount and nature of the personal data, potential risk of harm to data subjects from a data breach, and the applicable legal requirements.  If you have any questions about security at the Site, please contact us by email at info@repechage.com.

    1. YOUR RIGHTS AND CHOICES IN RELATION TO PERSONAL INFORMATION

    Updating Your Personal Information:

    • You can check, supplement and update your personal information at any time by contacting us at info@repechage.com.
    • You can deactivate your account at any time by contacting us at info@repechage.com.
    • You can change your marketing preferences at any time by contacting us at info@repechage.com.
    • To the extent that we offer you the option to save your payment information (i.e., credit card information), you can modify that information at any time in your account settings.

    Withdrawing Consent to Receive Direct Marketing:

    • You can withdraw consent to receive any direct marketing that you previously opted-in for by contacting us at info@repechage.com.

    Other Rights (Subject to Applicable Law):

    Subject to applicable law, you may have other rights regarding the collection and processing of your personal information.  These rights vary depending on the specific laws of the jurisdiction applicable to you, and the facts and circumstances surrounding the processing of personal information, but may include:

    • Right to access personal information – you may request a copy of the personal information we maintain about you by contacting us as described in the “Contact Us” section below.
    • Right to rectification of personal information if it is incorrect or incomplete – you can correct or update any personal information we have about you by contacting us as described in the “Contact Us” section below. If you are a registered user you can also log in to your account to correct or update certain information.
    • Right of erasure of personal information (i.e., right to be forgotten) if certain grounds are met - you may request for your personal information to be removed from our systems by contacting us as described in the “Contact Us” section below.
    • Right to restrict processing of your personal information if certain grounds are met- you may also ask us to stop or limit the processing your personal information by contacting us as described in the “Contact Us” section below.
    • Right to lodge a complaint with a supervisory authority - you may lodge a complaint with a supervisory authority. However, we ask that you contact us first (as described in the Contact Us section below) so as to allow us to address any concerns you may have before you approach the supervisory authority.
    • Right to withdraw consent (if processing is based on consent) – you can withdraw your consent as the legal basis for processing your personal information by contacting us as described in the “Contact Us” section below. If you withdraw your consent, our use of your personal information prior to your withdrawal remains lawful.  You can withdraw your consent to receive any direct marketing that you previously opted-in for by clicking the "unsubscribe" link at the bottom of any Opt-In Email you receive from us and following the instructions provided therein or by sending your opt-out request to info@repechage.com.
    • Right to object to processing (if processing is based on legitimate interests) - you may object to us using your personal data by contacting us as described in the “Contact Us” section below. Your rights may be limited if we have a compelling overriding legitimate interest for processing your personal information or if we need to continue to do so for legal purposes (i.e., for defending a legal claim).
    • Right of data portability (if processing is based on consent and automated means) – you may request a copy of personal information you have provided to us in a usable format by contacting us as described in the “Contact Us” section below. You may request that we send this personal information directly to another service provider if technically feasible.  We may not be able to provide a copy of your personal information if it concerns other individuals or if we have another lawful basis to withhold that information.
    • Right to object to decisions based on automated decision-making that produce legal or similarly significant effects on you - if certain grounds are met.

    Please note that the rights above may be limited in some circumstances under applicable law.  You may exercise the rights set forth above, to the extent they apply to you, by contacting us as described in the “Contact Us” section below. We may request reasonable additional information to authenticate your request and/or better understand it.  Where required by law, we will investigate your request and reply within one month of receipt of your request or within three months where a request is complex.

    1. COOKIES AND TRACKING TECHNOLOGIES
    • We, our service providers and other third parties may use "cookies" or similar tracking technologies to collect information about you. "Cookies" are small files that are sent from a server to your computer or mobile device when you visit a website and can be stored by the browser on your computer or mobile device.  When you revisit a website your browser sends these cookies back to the site so it can personalize your experience.  We may use cookies, or other similar technologies to help you navigate our Site, customize your visit to our site, save your settings and preferences and enhance your shopping experience.  We and our service providers may also use flash cookies to personalize your experience.  Some cookies may be deleted when you close your browser while others will be stored on your computer or mobile device until you remove them.  For example, cookies can be used to keep you logged in during your visit.  They can also be used to remember your login details when you revisit the Site. 
    • We and our service providers may use third party analytics cookies to help us understand and analyze how our visitors use our Site, what interests them the most, how they reach our Site, track conversions and provide analytics. Web browsers are usually initially set to accept cookies.  However, you can have your browser and/or plugs to your browser, such as flash, notify you of, or automatically reject, cookies.  If you reject our cookies, you may still use the Site, but you may be limited in the use of some of the features. 
    • We and our service providers may also use IP addresses and unique device identifiers to administer the Site, track traffic patterns, analyze trends and collect demographic information for aggregate use, as well as in combination with your personal information to comply with the law, or for credit fraud protection.
    • When you visit this Site or view one of our emails, we and our service providers may use pixel tags, web beacons, clear gifs, tracking links and/or other similar technologies to note some of the pages you visit on our Site or to determine what types of email your browser supports. We may also use these tracking technologies to measure conversions, count visitors, count users who have viewed our ads, opened our emails or clicked on any links.  We may use the information collected through pixel tags, web beacons, tracking links and similar technology to improve your experience. 
    • If you do not want information collected through the use of cookies, there is a procedure that allows you to decline the use of cookies in most browsers. Please refer to the Help button on your browser or go to the Help section on your Flash Player. To learn more about cookies, please visit http://www.allaboutcookies.org/.  You may not able to fully access our Site if you disable cookies. 
    • As mentioned, we may use service providers to help us with analytics. You may deactivate the ability of some analytics providers to collect information regarding your visit to our Site.  For more information, please visit http://optout.networkadvertising.org/?c=1#!/  Please note that this opt-out uses cookies.  If you delete your cookies, you will need to opt-out again.
    1. INTEREST BASED ADVERTISING
    • We may use certain third party advertising companies to help us tailor ads towards your interests and display them to you on other websites. We do this by allowing the third parties we work with to place cookies, pixel tags and other similar technologies on your computer or mobile device when you visit our Site.  The third party advertising companies may then use the information about your visit to the Site and other websites to provide advertisements for Repêchage products on this and other websites.  These companies also provide the information to us and we use it for marketing and business purposes, including measuring and evaluating the effectiveness of the ads displayed.  For more information about interest based advertising or how to opt-out, please see http://optout.networkadvertising.org/?c=1#!/  Please note that this opt-out uses cookies.  If you delete your cookies, you will need to opt-out again.
    • We may also run ad campaigns on social media which target our customers or the demographic profile of our customers. If you do not wish to see advertising that is tailored towards your interests on social media, please check the policies of the social media platform to see if it is possible to change your settings or opt-out. 
    1. CALIFORNIA PRIVACY RIGHTS
    • Under California Civil Code Section 1798.8, residents of California have the right to request, from a business with whom the California resident has a business relationship, certain information regarding the disclosure of personal information to third parties for direct marketing purposes. To make a request, please contact us at info@repechage.com or by mail an indicated in the “Contact Us” section.
    • If you are a California resident under 18 years old and a registered user of this Site, you have the right to request that we remove content or information that you have posted to our Site (for example, a product review). To make a request, please contact us at info@repechage.com or by mail an indicated in the “Contact Us” section.
    1. DO NOT TRACK

    Some browsers have a “do not track” option that allows you to tell websites that you do not want your online activities to be tracked.  Currently, we do not respond to browser “do not track” signals.

    1. CHILDREN

    This Site is not designed for children and we do not knowingly collect personal information from any children under 13.  If you are under 13 years of age, you may not and should not provide personal information to us. This means that you cannot make a purchase or register for the Site.

    1. LINKS

    The Site may contain links to or from other websites.  Your use of linked websites is at your own risk.  We make no representations or warranties with respect to the linked websites.  This Privacy Policy applies only to this Site.  We are not responsible for the privacy practices and data collection practices of other websites.

    1. MODIFICATION OF PRIVACY POLICY

    You understand and agree that we may revise this Privacy Policy at any time without notifying you. If we change our Privacy Policy, we will post the revised policy on this Site. Our rights to use your personal information will be based on the privacy policy in effect at the time the information is used.  We suggest that you check the Privacy Policy from time to time to review the most updated version.

    1. AGREEMENT TO PRIVACY POLICY

    By using the Site, you expressly agree to this Privacy Policy and to the Terms and Conditions.  If you do not agree then you should not use the Site.  If we change this Privacy Policy and/or the Terms and Conditions, your continued use of the Site following the posting of such changes shall constitute your acceptance of those changes.

    1. HOW TO CONTACT US?

    If you have any questions, requests or concerns about this Privacy Policy, or would like to exercise the rights and choices set forth above, please contact us by email at info@repechage.com or by postal mail in the U.S. at Sarkli-Repechage, Ltd., 300 Castle Road, Secaucus, NJ 07094, Attention: IT Department and in the UK at Repêchage Europe Ltd, Forest Mill, Water, Rossendale, Lancashire BB4 9BF, Attention: Managing Director.                If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority.  We would, however, appreciate the chance to address your concerns before you contact the supervisory authority and ask that you contact us in the first instance.